Assessment and Collection of Regulatory Fees for Fiscal Year 2021 - Comments of CCIA, DiMA, INCOMPAS and Internet Association

Sep 4, 2026

These comments to the Federal Communications Commission address the proposed assessment and collection of regulatory fees for fiscal year 2021. The submitting associations urge the FCC to keep regulatory fees fair, administrable, and sustainable, and to maintain the current base of payors. They argue that expanding fee contributors could effectively function as a “Wi-Fi tax” on users and related entities, and that some proposed fee categories would be unworkable or too narrowly defined for effective administration. The filing also highlights how unlicensed spectrum supports investment, innovation, and consumer choice.

LanguageEnglish

CategoryResearch & Report

FormatPDF

Pages10

Reading Time25 min

AccessFree to download

Introduction and Summary

The Associations’ position on regulatory fee categories

The FCC’s approach to unlicensed spectrum users

Investment, innovation, and consumer choice

Before the Federal Communications Commission Washington, DC In re Assessment and Collection of Regulatory Fees for Fiscal Year 2021 Docket No. 21-190 COMMENTS OF CCIA, DiMA, INCOMPAS AND INTERNET ASSOCIATION The Computer & Communications Industry Association, Digital Media Association, INCOMPAS, and Internet Association (Associations) submit these comments in response to the Notice of Proposed Rulemaking (NPRM) in the above-captioned proceeding seeking comment on whether the Federal Communications Commission (FCC or Commission) should adopt new regulatory fee categories and on ways to improve the regulatory fee process regarding any and all categories of service. 1 I. INTRODUCTION AND SUMMARY The Associations ’member companies represent a broad cross-section of the most innovative technology and communications companies in the United States who have invested significant resources and delivered unprecedented value to consumers through products and services that rely upon unlicensed spectrum. The Associations greatly appreciate the Commission’s significant efforts to make unlicensed spectrum available as a public good that has enabled innovative products and services, and recognize that the Commission’s regulatory fees are important to fund its vital activities to regulate a broader industry of communications services providers and spectrum license holders. In these comments, the Associations encourage the Commission to ensure that regulatory fees are consistent with its statutory requirements to be fair, administrable, and sustainable, and appropriately reflect the Commission’s core work to regulate spectrum licensees and communications service providers who directly benefit from the work of the FCC. The questions raised in the NPRM to expand the base of contributors of regulatory fees, however, could amount to a tax on Wi-Fi users, service providers, 1 Assessment and Collection of Regulatory Fees for Fiscal Year 2021, Report and Order and Notice of Proposed Rulemaking, MD Docket No. 21-190, FCC 21-98,(rel. August 26, 2021) (“NPRM”) . equipment manufacturers, and other entities that are delivering innovative products and services that rely on unlicensed spectrum (Wi-Fi tax), and may have little engagement with the Commission. Moreover, the regulatory fee categories proposed by certain parties, such as “unlicensed spectrum users” or“especially large technology companies,”would be unworkable or arbitrarily narrow for the Commission to effectively administer, and beyond the scope of the Commission's legal authority to impose fees on entities “that are reasonably related to the benefits provided to the payor of the fee by the Commission’s activities.”2 For these reasons, the Associations urge the Commission to maintain the current base of regulatory fees payors and reject any suggestions to expand the scope of such fees that commenters may raise in response to the NPRM. II. THE COMMISSION’S APPROACH TO UNLICENSED SPECTRUM USERS HAS UNLEASHED SIGNIFICANT INVESTMENT, INNOVATION, AND CONSUMER CHOICE As Acting Chairwoman Jessica Rosenworcel has said,“No matter who you are or where you live, the odds are good that you have benefited from unlicensed airwaves and Wi-Fi.”3 Similarly, Commissioner Brendan Carr has noted that increasing the availability of unlicensed spectrum will add nearly $200 billion to the U. S. economy and unleash a new wave of virtual reality applications for education, commerce and other “next-gen connection” applications.4 Indeed, almost every American consumer and business has benefited from unlicensed spectrum.5 Fully realizing the value of this unlicensed spectrum requires technology companies to create products and services to use this spectrum. In recent years there has been a dramatic increase in the number of innovative connected devices, providing immeasurable benefits for consumers through unlicensed spectrum. Consumers use devices 2 47 U. S.C. § 159(d) (emphasis added) .

FAQs

What is the main purpose of these FCC comments for fiscal year 2021 regulatory fees?

The associations submit comments responding to the FCC’s notice of proposed rulemaking on whether to adopt new regulatory fee categories and how to improve the regulatory fee process across service categories.

Why do the associations oppose expanding the base of regulatory fee contributors?

They contend that expansion could amount to a “Wi-Fi tax” on Wi-Fi users, service providers, equipment manufacturers, and other entities with limited engagement with the FCC.

What concerns do the associations raise about proposed fee categories like “unlicensed spectrum users”?

They argue such categories would be unworkable or arbitrarily narrow, making it difficult for the FCC to administer them effectively and within its legal authority.

Sep 4, 2026

Uploaded by Olivia Brown